Policy/Action: The revised policy provides the Office of Management and Budget’s (OMB) exception to post single source awards on Grants.gov and removes the dollar threshold requirement for Solicitor review.

Single source awards are funding opportunities to a known recipient when deemed appropriate and that meet demonstrable criteria. When a single source award over $25,000 is justified, the Grants Management Officer (GMO) is required to post a Notice of Intent (NOI) on Grants.gov. The NOI provides public notice of the intent to award without competition. However, with the impending implementation of the BLM’s new Financial and Business Management System (FBMS), which will require mandatory electronic submissions of grant applications, all NOIs, regardless of the dollar amount, must be posted on Grants.gov. After FBMS implementation, if the application and associated paperwork are not submitted electronically, the GMO will be required to personally enter the data before the financial assistance is awarded.

Solicitor review of grants and cooperative agreements is no longer required at any dollar value. The GMOs are encouraged to request a Solicitor review if the circumstances warrant. Factors to consider in deciding whether to request a Solicitor review include dollar value, complexity, and potential for controversy or other factors identified by the GMO.

Timeframe: This IM is effective upon issuance and applies to all grants and financial assistance agreements awarded under 43 CFR Part 12.

Budget Impact: None

Background: The Departmental Manual Release, 505 DM 2, updates the DOI policy on procurement contracts, grants, and cooperative agreements, which upholds the use of appropriate instruments for acquiring goods and services or in providing financial assistance. The policy was revised to provide guidance when working with known partners and incorporates OMB provisions allowing an exception to posting single source awards on Grants.gov. It provides criteria for justifying single source awards and establishes accountability through periodic compliance reviews and appropriate documentation.

The revision changes the role of the Solicitor’s Office to provide legal review where it is most needed for Federal financial assistance programs. Review is only necessary for the development of new programs and policies or when a proposed cooperative agreement or grant is of such complexity or novelty that a legal review is warranted. The threshold of $750,000 and above requiring Solicitor review of grant and cooperative agreement awards is eliminated.